The ITAT remands BorgWarner’s case on TSS, BSS, and royalty benchmarking to TPO for re-determination, questioning the segregation approach used for international transactions.
Delhi HC rules reimbursements to NRAEs not subject to TDS as “fees for technical services,” clarifying scope of Section 9(1)(vii) and TDS under Section 195.
Explore how LLCs qualify for India-US DTAA benefits, focusing on tax liability and resident status under Article 4 in the General Motors vs ACIT case.
Delhi High Court clarifies taxability of profits attributed to a Permanent Establishment (PE) under the India-UAE DTAA, even when global losses are incurred.
Tiger Global International III Holdings Vs Authority for Advance Rulings (Income- Tax) & Ors. (Delhi High Court) The Delhi High Court delivered a significant judgment in the case of Tiger Global International III Holdings v. The Authority for Advance Rulings (Income-Tax) & Ors., reaffirming the importance of the Tax Residency Certificate (TRC) in international tax […]
This article delves into regulatory uniformity, addressing challenges and the role of harmonization in fostering a resilient financial ecosystem.
Understand how Changeability of Income Tax affects Family Investment Funds (Company/LLP) in the IFSCA Fund Management Regulations. Learn how the set up of a FIF in IFSC’s can help you invest globally with a closer to the ground Indian approach.
Explore landmark cases like SAP Labs vs. IT Officer, Evalueserve vs. Commissioner, and Softbrands vs. IT. Learn how the law and facts intersect in transfer pricing disputes.
Understand what qualifies as ‘stewardship activities’ for taxation in India with the Supreme Court’s single-entity approach. Taxes on stewardship activities, Morgan Stanley & Co v India judgement explained
Explore intricate relationship between income tax and customs valuation. Learn how these realms intersect, challenges they pose, and strategies for harmonization.